Opening the Door to CE Marking
This article provides an introduction into CE marking of pedestrian doorsets with fire and/or smoke control characteristics. It also reviews some of the frequently asked questions received from manufacturers who have achieved third-party certification via the BM TRADA Q-Mark Fire Door Manufacture scheme and from members of the Architectural Specialist Door Manufacturers Association (ASDMA).
The Construction Products Regulation (CPR) introduced the most significant regulatory change for a decade in the way that construction products are manufactured and sold in the European Union (EU). The CPR replaced the Construction Products Directive (CPD) and made CE marking mandatory across the entire European Union (EU), for products defined by relevant harmonised European Product Standards (hEN). The CPR will have the greatest impact in the UK, Ireland and Sweden, where CE marking was voluntary under the CPD.
It is imperative that manufacturers of construction products understand the requirements placed on them by the CPR but importers, exporters, distributors, designers, specifiers and builders must also make themselves familiar with the legislation. Many construction product manufacturers will be unfamiliar with the process of CE marking and some will be unaware of the legal obligations now placed on them by the requirements of the CPR.
What is the CPR?
The CPR, which came into effect on 1st July 2013, had several fundamental aims:
- To break down technical barriers to trade in construction products, enabling free movement of products across the European Union.
- To provide for a system of harmonised technical specifications that have reached the end of the co-existence period.
- To establish harmonised rules for expressing the performance of construction products.
- To set up a framework of Notified Bodies (bodies authorised by the EU to perform testing and certification).
- To enable the CE marking of products.
The building regulations in Member States will still apply. Furthermore, the CPR does not affect the specification of actual construction works because the public and private sectors are free to set their own requirements for the performance of buildings and construction works, and therefore the performance of construction products. However, by specifying CE-marked products, specifiers can be confident that supplied products will consistently meet minimum performance standards.
These minimum performance standards are detailed in harmonised European product standards (hENs) that define methods of assessing and declaring all the essential performance characteristics. These characteristics, required by regulations in any Member State, relate to the ability of construction products to meet basic requirements for construction works, including safety in case of fire.
Fire Resisting Doorsets
In the UK and Ireland there are two main routes via which a fire-resisting doorset can be supplied and installed within a building to comply with building regulations:
1 The door leaf and its component parts (door frame, hardware, seals etc.) are supplied by different companies under separate contracts for construction and installation on site (door assembly). Not CE markable.
2 The doorset is supplied by one company under a single contract either fully or part assembled for installation on site. Any further works required for the door are typically carried out using basic tools in order to fit the hardware or seals (doorset). CE markable.
The CE marking requirement under the CPR only relates to doorsets that are supplied as a warranted, tested whole from one legal entity or company under a single contract. These doorsets must comply with a range of essential requirements once CE marking of fire resisting doorsets becomes mandatory.
Under the CPR, pedestrian doorsets with fire and/or smoke control characteristics are covered by a draft hEN, pr EN 16034. This has yet to be finalised and it is for this reason that it is not currently a mandatory/legal requirement for manufacturers to CE mark such doorsets in order to place them on the open market. However, when pr EN 16034 is published as a full standard and the co-existence period has finished, all manufacturers of such doorsets must comply with the product standard under the CPR, and CE mark the doorset before placing it on the open market.
Although a co-existence period has been requested, it has not been confirmed how long such a period would be or whether it will be granted. Without a co-existence period (or after it has ceased), technically it will be illegal for a manufacturer to place a fire resisting doorset on the open market without a CE mark.
The CE Marking Process
Responsibility for completing the various stages of the CE marking process for construction products varies depending on how safety critical the product is. The more critical, the greater ‘third-party’ involvement is required.
Fire resisting doorsets are deemed safety-critical and as such require a Notified Body, such as BM Trada, to carry out the initial type testing, factory production control (FPC) inspection and ongoing FPC surveillance.
The manufacturer must make a declaration of performance (DoP) for the product before placing it on the market. The manufacturer must then take responsibility for the conformity of the construction product to this DoP. The DoP will express the performance of the construction product in relation to a list of ‘Essential Characteristics’ defined in Annex ZA of the hEN. These must be referred to both in the DoP and in the CE Mark.
All these characteristics need to be considered by the manufacturer, but there are only a few against which a performance must be claimed. These essential characteristics are mandatory in the UK and, in the case of pedestrian doorsets with fire and/or smoke control characteristics, include fire resistance performance, smoke control and durability.
A classification document assists with the DoP and, for doorsets with fire and/or smoke control characteristics, BS EN 13501-2 specifies the procedure for classification of construction products from fire resistance and smoke leakage data. A classification document essentially provides information on the tested characteristics of a doorset and the performance that it can provide.
In addition to classification documents, as part of the CE marking process, a manufacturer can extend the scope of application for their product by a direct field of application report (DIAP) or extended field of application report (EXAP). DIAP rules are given in the test standard for the product, which is BS EN 1634-1 in the case of fire performance and doorsets. A DIAP report is generally quite limited in the changes it permits for the doorset design.
An EXAP provides a wider scope of design options and, in the case of fire-resisting timber doorsets, is governed by the rules given in BS EN 15269-3. Smoke control doorsets are governed by BS EN 15269-20. A manufacturer chooses to have these documents written, based on their test results in order to enable them to offer the widest scope of products to the market that can also carry the CE mark. It is possible to classify a product’s performance on the back of DIAP and EXAP reports.
As well as the DoP, the manufacturer must also affix the CE mark according to a legal format. It must be attached visibly, legibly and indelibly to the product, its packaging or the manufacturer’s commercial documentation accompanying the product. In the case of fire resisting doorsets, a Notified Body must be involved in the factory production control phase and the Notified Body’s identification number must also be displayed.
Essentially it is the manufacturer’s responsibility to prove that the doorsets with fire and/or smoke control characteristics they are supplying to market meet the necessary requirements as stated in the hEN.
With any new legislation there are always questions regarding implementation and interpretation. But by getting a product ready for the market, manufacturers can gain competitive advantage, or at the very least, remain in the marketplace once the legislation becomes mandatory.
It makes sense for all manufacturers of doorsets with fire and/or smoke control performance characteristics to understand the CE marking process and prepare for its implementation. CE marking of certain construction products is already here and, while it is impossible to say for sure what the future holds, it is important to be prepared.
Frequently Asked Questions
At first glance, the process of CE marking fire resisting doorsets seems very different to the current situation in the UK and Ireland, not least because of the technical language used. Understandably, manufacturers have many questions regarding compliance with their legal obligations.
BM TRADA has compiled some frequently asked questions received from BM TRADA Q-Mark certified door manufacturers and members of the Architectural Specialist Door Manufacturers Association (ASDMA). The answers provided are to the best of our knowledge at the time of going to press:
- Who needs to CE mark?
Manufacturers of construction products that are covered by harmonised product standards (hENs). Fire resisting doorsets that are constructed and supplied to market by one manufacturer will need to CE mark their doorsets under the requirements of hEN 16034 when published.
- When will it come into effect?
BM TRADA’s current best estimate for pr EN 16034 to become a full standard is May 2015. A co-existence period has been requested but is yet to be confirmed. Once it comes into effect and any co-existence period has expired it will be a requirement to CE mark fire resisting doorsets.
- I am only supplying the door leaf; will this need to be CE marked?
No. It will be the responsibility of the doorset manufacturer to use the correct door leaf as tested for the complete doorset. It is not possible to CE mark a door leaf. The door leaf may need to be sampled at factory source prior to testing.
- If a door manufacturer only supplies the leaf for others to install into a suitable and compliant door frame with appropriate hardware and intumescent seals etc, as supported by the test evidence, is the door manufacturer in contravention of the Construction Products Regulations when they come into force?
No, this is the definition of providing doorsets as a door assembly. It is BM TRADA’s understanding that it will be possible to continue to supply different door components for construction and installation on site from various manufacturers and under different contracts. However, if a CE marked doorset has been specified this route will not be acceptable. It is likely that the requirement for CE marking will be driven by market requirements.
- Can I use any CE-marked hinge on fire doors or does it have to be as the tested specification?
BM TRADA’s current understanding is that alternative CE-marked hinges can be cascaded into a doorset manufacturer’s EXAP report. However, the test evidence for the hinge must be submitted to the Notified Body writing the EXAP report (a DoP on the hinge is not sufficient as the only documentation) and the evidence for the hinge must be on a door of a similar product family.
- My proposed hinge blade is bigger than the permitted hinge blade in the EXAP but it is CE marked, will this be acceptable?
Only if the CE-marked hinge has been tested on a doorset of a similar product family and is subsequently included within the EXAP for the door design.
- A flush CE marked doorset has been installed but now I need to fit a glazed aperture in it, is this allowed?
CE marking follows the Chain of Custody approach that those involved with third party certification of products will already be familiar with. CE marking is a declaration by the manufacturer that the products meet basic safety requirements for selling on the open market. If changes are made to the doorset after it has been manufactured and installed the Chain of Custody is broken and any assurances that the product met these performance requirements when it left the factory would be void.
- I will be manufacturing a CE-marked doorset in a frame with essential hardware but not installing it as it will be painted on site, do I need to CE mark and if so, how do I do this if it is still to be painted?
If the doorset is constructed and supplied to market by one manufacturer it should be CE-marked. The doorset can then be decorated on site by others.
- Will architects be required to specify the handles (levers and pulls) tested as part of the CE-marked doorset or will there be an allowance for architects to specify a CE-marked doorset supplied by one company and the handles supplied by another company?
If the specification calls for a CE-marked doorset, it will have to be provided by one doorset manufacturer who has had the handles considered suitable for use with their doorset design as part of the scope of application using the EXAP process or, if necessary, by testing.
- External pedestrian doorsets must already carry a CE mark, what if these doors also need to provide fire resistance?
Until the hEN for fire-resisting doors is published as a full standard it will only be possible to CE mark external pedestrian doorsets to EN 14351-1 and then also declare the fire resistance of the door outside of the DoP.
For further information, go to www.bmtrada.com/testing